Stuart Finlay

771 Inman Mews Drive NE Atlanta, GA 30307

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington DC 20590

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 C.F.R 91.145(b); 14 CFR 91.151(a); 14 CFR 91.203 (a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1); 14 CFR 91.409 (a)(2); 14 CFR 91.417(a) and (b)

To Whom It May Concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14
CFR Part 11. I, Stuart Finlay

, sole

- owner of Wired Technology Company LLC and operator of an Unmanned Aircraft System (UAS), DJI F550 , hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its UAS, so long as such operations ar e conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333.

Commercial operation of an UAS, as described herein, which are equipped with camera(s) and sensors, would operate in the following manner:

 Aerial photography and/or video for public and/or private use including real estate, architecture, land surveying, engineering and other related professional activities.

 Aerial video and/or photography for public and/or private use including tele vision, public/sporting events, cinematography, and news gathering.

 Aerial inspection/photography of residential/commercial structures under contract with the owners or local government authority.

 Aerial video/photography of the aftermath of wildfires and drought conditions

.

 Aerial video/photography or providing live video feed to assist with search and rescue operations in cases of an emergency or natural disaster only when the local authorities o r government has requested it by contract or donation.

 The ability to offer training to persons individually or belonging to both private and/or public organizations that have interests in the use and application of a UAS for the purpose of the safe

opera tion of a UAS to enhance the safety of the National Airspace System (NAS) as well as for the protection of the persons and property.As described fully below, the requested exemption would permit the operation of a UAS under

controlled conditions in the NA S that would be a) limited b) controlled c) predetermined and d) will provide safety enhancements to the already safe operations in the industry presently using conventional aircraft. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “....establish requirements for the safe operation of such aircraft systems in the national airspace system.”

The name and address of the applicant is:

Wired Technology Company LLC

Attn: Stuart Finlay
Address: 771 Inman Mews Drive NE Atlanta, GA 30307
Ph: 404

- 969

- 6252
Email: stuart@wiredtechco.com

Regulations from which the exemption is requested:

14 CFR Part 21 subpart H

14 CFR 45.23 (b) 14 CFR 61.113 (a) & (b) 14 CFR 91.7 (a) 14 CFR 91.9 (b) (2)

14 CFR 91.103

14 CFR 91.109 14 CFR 91.119 (c)

14 CFR 91.121 14 C.F.R 91.145(b) 14 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a) 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a) (2)

14 CFR 91.417 (a) & (b)

Wired Technology Company LLC will operate the DJI F550 , with a maximum total weight of 3 7 5 0 g or 8.267 lbs

. The dimensions are 592 mm x 528 mm x 3 50 mm or 23

. 25 x 20 .7 5 x 13.75 inch es . Under still air the maximum speed is n o more than 20.25m/s or 45.3 mph with a cruising speed of 11m/s or 25mph.
The DJI F550 has the ability to hover and move along a vertical and horizontal plane simultaneously. The

DJI F550 has six motors, Motor Model SunnySky x2212 980kV, powered by a 4

- cell 16,000 mAh or 3

- cell

75 00mAh Lithium Polymer battery. There are six propellers, Propeller Model Gemfan 1 047 , in use. The

DJI F550 will be controlled with the Turnigy 9XR Pro remote controller with an operating frequency of

2.400GHz

– 2.483GHz. The live video feed wil l have an operating frequency of 5.728GHz

– 5.850GHz. The applicant will operate the UAS in line of sight within a closed off and predetermined area owned and/operated by the property representative. The DJI F550 has an app called The Tower which allows
th e Pilot to monitor all aspects of the flight on the HUD. Attached along with this exemption request are all of the necessary documents and safety features of the DJI F550

.Given the small size of the UAS and the controlled environment provided the propose d operations will

adhere to the Reform Act’s safety requirements. The approval of this application presents no national security issues. Regarding the level of safety surrounding the proposed operations and the public benefit, reduction in environmental im pacts, including but not limited to reduced emissions and noise, the grant of the requested exemption is in the public interest. Accordingly the applicant requests that the FAA grant the requested exemption with minimum delay.

AIRCRAFT AND EQUIVALENT LEVE L OF SAFETY

The operation limitations proposed for an equivalent or higher level of safety because operations will further enhance the safety of the persons and/or property using conventional aircraft.
These limitations and conditions to which the applicant agrees to adhere to when conducting commercial operations under the FAA issued exemption as set forth in the Flight Operations Manual (FOM) include:

 The UAS will weigh less than 55 lbs.

 The UAS will have a maximum operating speed of no more tha n 50mph.

 Flights will be operated within line of sight of the Pilot in Command (PIC) and/or Visual Observer (VO).

 Maximum flight time for each operational flight will be 30 minutes. Flights will be terminated at 30% battery power reserve or 30 minutes of flight time whichever occurs first.

 Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL) and not more than 200 feet above an elevated platform from which filming is planned.

 Minimum crew for each operation will consist of the UAS Pilot, the Visual Observer (VO) and may include but not limited to a Camera Operator.

 The UAS pilot will be a designated Pilot in Command (PIC) and hold a Commercial Pilot’s License. If the PIC feels another operator to be qualified wit h the necessary skills to be PIC & possess a Commercial Pilot’s License, that person may be designated PIC provided they have a minimum of 50 hours of flight time with the UAS.

 A briefing will be performed regarding the planned UAS operations prior to eac h day’s flight consisting of all the days’ production activities.

 All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only. In addition, an anemometer will be used prior to flight to measure wind speed, and atmospheric pressur e in current flight location.

 The flights will occur no closer than a 5 mile radius of the geographic center/Airport Reference Point (ARP) of a tower controlled or uncontrolled airport. If operations will be within a 5 mile radius of the geographic cente r/ Airport Reference Point

(ARP) of a tower controlled or uncontrolled airport the respective airports will be contacted advising them of the estimated flight time, flight duration, elevation of flight and other pertinent
information.

 The operator will fi le FAA Form 7711

- 1, or its equivalent, as modified in light of the requested exemption, with the appropriate local Flight Standards District Office (FSDO) no more than 72 hours but no less than 48 hours from planned operation.

 The operator will obtain ver bal/written consent of all persons involved with the planned operation and ensure that only consenting persons will be allowed within 100 feet of the flight operation, and the radius may be reduced to 30 feet based upon an equivalent level of safety
determ ination, as required under the FOM. With the advanced permission of the FSDO, operations at closer range may be approved.

 The PIC and VO will have been trained in operation of UAS and receive up

- to

- date information for the particular UAS to be operated.

 The PIC and VO will be able to communicate by voice, radio, and/or text at all times.

 Written and/or verbal permission and permits will be obtained from territorial, state, county or city jurisdictions, including law enforcement, fire or other appropriate governmental agencies.

 If the UAS loses communications with the remote controller or loses GPS signal, the UAS will have the capability to return to a pre

- determined location within a designated location and land autonomously.

 The UAS will have the capa bility to abort a flight in case of unpredicted obstacles, weather, or emergencies.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements of an equ ivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate, in t he restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed.

The UAS t o be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured and designated area. Unlike other civil aircraft, operatio ns under this exemption will be tightly controlledand monitored by both the operator and under the requirements and in compliance with local public

safety requirements. The FAA will have advance notice of all operations. These safety enhancements provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of
these same criteria demonstrates that there is no credible threat to national security posed by the UAS, due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial e xternal load.

14 C.F.R. § 45. 23 (b). Marking of the Air craft

The regulation requires: When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light

sport," "experimental," o r "provisional," as applicable.

Eve n though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. Given the size of the UAS, two

- inch lettering will b e impossible. The word “Experimental” will be placed on the fuselage in compliance with §45.29 (f).

The equivalent level of safety will be provided by having the UAS marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the UAS will see the identificatio n of the UAS as “Experimental.”

14 C.F.R. § 61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in Command.

Pursuant to 14 CFR 61.113 (a) & (b), no person who holds a private pilot certificat e may act as a pilot in command of an aircraft that is carrying passengers or property for compensation or hire. Wired Technology Company LLC may achieve an equivalent level of safety as achieved by current Regulations because the applicant’s UAS do es not carry any pilots or passengers nor property. The risks attendant to the operation of UAS is far less than the risk levels inherent in the commercial activities outlined in 14 CFR 61. The PIC of the UAS will have a Private Pilot’s License along with a minim um of 50 hours of flight time which exceed the safety levels in relation to 14 CFR 61.113 (a) & (b). I feel the operation and limitations set forth in the FOM will equate to the safe operation of the UAS.

14 C.F.R. §91.7(a) : Civil Aircraft Airworthiness.

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for det ermining airworthiness. Given the size of the aircraft for maintenance and use of safety check lists prior to each flight an equivalent level of safety will be provided. Prop locks have been issued for this aircraft so the possibility of a prop flying off mid

- flight is
inevitable which also a chieves a higher safety factor.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.Section 91.9 (b) (2) provides: No person may operate a U.S.

- registered civil aircraft ... (2) For which an

Airpla ne or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. The UA S, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft. The equivalent level of safety will be maintained by keeping the flight manual at the ground control point where the pilot flying the UAS will have immediate access to it. If for some reason the Pilot forgets the flight manual, The DJI Pilot app has all documentation indicated in the hard copy manual, electronically built into the application on your smart phone or tablet.

14 C.F .R. § 91.103: Preflight Action.

This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption
will be needed. The PIC will take all actions as stated in the FOM in Section 4 under Normal Procedures including but not limited to reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight. Before the aircraft takes flight, a home GPS location will be set for any reason the aircraft becomes disoriented in fli ght, and return safely
to home.

14 C.F. R. §91.109: Flight Instruction.

Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. UAS and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. The equivalent level of safety provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the

size an d speed of the aircraft.

14 C.F.R. § 91.119: Minimum Safe Altitudes.

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a UAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400 AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption may be needed to allow such operations. As set forth herein, the UAS will never operate at higher than 400 AGL with the exception that in circumstances where the UAS is used to survey or phot ograph a structure whose height exceeds 400 feet AGL, the UAS will not be operated more than 200 feet above the highest point on the structure. It will however be operated in a restricted area with security perimeter, where buildings and people will not be exposed to operations without their pre

- obtained consent. It also may be operated over open water close to shore keeping a distance of 500 feet as

i ndicated in Section 91.119 (c).The equivalent level of safety will be achieved given the size, weight, sp eed of the UAS as well as the

location where it is operated. No flight will be taken without the permission of the property owner or local officials. Because of the advance notice to the property owner and participants in the filming activity, all affected individuals will be aware of the planned flight operations. Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 55lbs. proposed herein and the lack of flammable fuel, any risk associated with these operations is f ar less than those presently presented with conventional aircraft operating at or below 500 AGL. In addition, the low

- altitude operations of the UAS will ensure separation between these UAS operations and the operations of
conventional aircraft that m ust c omply with Section 91.119.

14 C.F .R. §91.121 Altimeter Settings.

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set “...to the elevation of the departure airport or an appropr iate altimeter setting available before departure.” As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the safety chec k list and live flight data monitoring, confirming the altitude of the launch site shown on the GPS altitude indicator before flight. The DJI F550 uses DJI Vision Positioning. It is a positioning system that uses ultrasonic and image data to help the aircr aft identify its current position. With the help of Vision Positioning, the F550 can hover in place more precisely and fly indoors or in other environments where there is no GPS signal available. The main components of DJI Vision Positioning are located on the bottom which include two sonar sensors and one monocular camera. This provides a significant level of safety.

14 C.F.R §91.145(b) Management of aircraft operations in the vicinity of aerial demonstrations and majo r sporting events

CFR 91.145 states:

(b) In deciding whether a temporary flight restriction is necessary for an aerial demonstration or major sporting event not listed in paragraph (a) of this section, the FAA c onsiders the following factors: (1) Area wher e the event will be held. (2) Effec t flight restrictions will hav e on known aircraft operations. (3) Any existing ATC airspace traffic management restrictions. (4) E stimated duration of the event. (5) Degree of public interest. (6) Number of spectators. (7) P rovisions for spectator safety. (8) Number and t ypes of participating aircraft. (9) Use of mixed hig h and low performance aircraft. (10) Impact on non

- participating aircraft. (11) Weather minimums. (12) Emergency pro cedures that will be in effect.

If Wired Technology Company LLC intends to use the UAS to cover sporting events from outside the activity, coordination will be completed by contacting the FSDO prior to the event to ascertain the presence of any other unmanned activities. Flight activity will be conducted based on safe ty and withparticular attention to the avoidance of overflight of large concentrations of people. However, specific

relief from this regulation is still necessary to ensure compliance with FARs.

14 C.F.R. § 91.151(a): Fuel Requirement s for Flight in VFR Conditions

Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing, and, assuming normal cruising speed

- (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.”

The battery powering the UAS provides approximately 30 minutes of powered flight. To meet the 30

minute rese rve requirement in 14 CFR §91.151, UAS flights would be limited to approximately 10 minutes in length. Given the limitations on the UAS’s proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight in daylight or twiligh t
VFR conditions is reasonable.

Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. Operating the UAS, in a tightly controlled area where only people and property owners or o fficial representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to alleviate given the size and speed of the small UAS. Additionally, limiti ng UAS flights to 10 minutes would greatly reduce the utility for which the exemption will be granted. Applicant believes that an equivalent level of safety can be achieved by limiting flights to 30 minutes or 30% of battery power

— whichever happens first. This restriction would be more than adequate to return the UAS to its planned landing zone from anywhere in its limited operating area.

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration

The regulation p rovides in pert inent part:

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the following:

(1) An appropriate and current a irworthiness certificate. . . .

(b) No person may operate a civil aircraft unless the airworthi ness certificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit
entrance so that it is legible to passengers or crew.

The UAS fully loaded weighs no more than 55 lbs. a nd is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents or to display them on the

UAS.

An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the UAS will have immediate access to them, to the extent they are applicable to the UAS. Again if Pilot forgets documents, all doc uments can be achieved via the DJI Pilot App.

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.These regulations require that an aircraft operator or owner “shall have that aircraft inspected as

prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircr aft in compliance wi th Part 43.

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to the flight manual and operating handboo k. An equivalent level of safety will be achieved because the UAS is very limited in size and will carry a small payload and operate only in restricted areas for a limited period of time. If mechanical issues arise the UAS can land immediately and will be operating from no higher than 400 feet AGL. The operator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. Most importantly, the operator is the person most f amiliar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety.

An equivalent level of safety will be achieved because maintenance and inspections will be performed in
accordance with the UAS Manufacturer's User Manual. As provided in the FOM, the operator will ensure that the UAS is in working order prior to initiating flight and perfo rm required maintenance needed.

Additional Information

The applicant, Stuart Finlay , has been invol ved in the building and the piloting of remote controlled aircraft for more than 10 years. He has logged more than 900 hours on RC Helicopters, Planes, and UAS.

He currently ha s logged more than 150 hours on the F550 between the b uilt in flight simulator on The Tower pilot app that simulates the true functionality of the aircraft to authentic flying in real life scenarios. Also the primary pilot, Stuart Finlay , has an in

- depth understanding of the capabilities and safety concerns involved in using this tec hnology as an asset to the community. The technology can be used in such a way that it benefits the community as a whole and can educate future pilots in a safe environment. The satisfaction of criteria provided in Section 333 of the Reform Act of 2012 pro vides a level of safety that should be satisfactory to the FAA and general public. In view of the beneficial advantages to public safety, I respectfully submit my Section 333 exemption request for allowing the commercial op eration of the applicant’s UAS.

Sincerely, 

## Stuart D. Finlay
Stuart Finlay

Wired Technology Company LLC

Attn: Stuart Finlay

771 Inman Mews Drive NE Atlanta, GA 30307 stuart@wiredtechco .com